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2012-05-04_GENERAL DOCUMENTS - C1981008
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2012-05-04_GENERAL DOCUMENTS - C1981008
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Last modified
8/24/2016 4:57:19 PM
Creation date
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DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
General Documents
Doc Date
5/4/2012
Doc Name
Defendants Reply Brief in Support of Motion to Dismiss for Lack of Subject Matter Jurs 2010 CV 367
From
Christopher Kamper, Craig R. Carver, Carver, Schwarz, McNab & Baily, LLC
To
District Court Montrose County Colorado
Permit Index Doc Type
General Correspondence
Email Name
DAB
Media Type
D
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No
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attempted to challenge through the vehicle of a breach of contract claim certain rates and their <br />implementation set by the utility. However, those rates were in turn set by a statutory procedure <br />involving the Public Utilities Commission, and the plaintiff municipality had not challenged the <br />PUC's approval of the rates. City of Boulder, 996 P.2d at 203. <br />In dismissing the plaintiff's contract cause of action, the Court of Appeals had no trouble <br />seeing through the form of action to the underlying allegations. See, 996 P.2d at 203 ( "Where <br />administrative remedies are available and have not been exhausted, the courts lack subject matter <br />jurisdiction and the case must be dismissed. ") Id. It did not matter that there was a contract <br />involved. Here, similarly, the only breaches of contract actually alleged in the FAC are those <br />that were reviewed and rejected by the Division, which plaintiffs failed to appeal. <br />B. The Savings Clause Does Not Save Plaintiffs. <br />Plaintiffs attempt to rely upon the savings clause of CRS 34- 33- 135(5) to get around the <br />exhaustion requirement. Response Brief at 4. This reliance is misplaced because plaintiffs fail <br />to give effect to the plain language of that statute. First, the savings clause starts by saying <br />"[n]othing in this Section" — i.e., Section 135 of Article 33 of Title 34 — has the effect described <br />in the savings clause. Section 135 creates the citizen suit cause of action. The remedies <br />plaintiffs failed to exhaust arise under a different section, CRS § 34- 33- 124(a). The savings <br />clause does not refer to such remedies. Second, that savings clause only saves rights that that a <br />person "may have" — i.e. which are otherwise valid — under "any statute or the common law" to <br />seek "allowable relief." CRS § 34- 33- 135(5). This begs the very question of whether the relief <br />plaintiffs seek in this case, based on the allegations of the FAC, is "allowable" under other law. <br />The import of the savings clause is to save valid claims, not to create an exception for otherwise <br />invalid claims to proceed. <br />4 <br />
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